This is your chance to "bend the rudder" of government.Â There are many "stakeholders" who wish to alter how you practice medicine through use of the EHR.Â Â Attached (below) is a link to download the document.

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The HIT Policy Committee (HITPC) has developed a preliminary set of recommendations specifically designed to solicit additional public feedback. The goal of sending out this request for comment (RFC) early is threefold.

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Provide some signal to the industry of potential new EHR functionalities that the HITPC may recommend to help the industry get a head start on developing new functionalities.

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Extend the public discussion of future stage MU definitions through a more formal public comment process well in advance of its formal final stage 2 recommendations to be issued in the summer of 2011.

If you are searching for the notice online to submit an electronic comment, use the following website http://www.regulations.gov and the following "Keyword or ID"

HHS-OS-2011-0006-0001

Jamie Loehr

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Here is my comment - submitted Feb 6, 2011

I have several comments about the proposed Meaningful Use Objectives and Measures for Stages 2 and 3.

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First, the eRx requirement of 80% for stage 3 is extraordinarily high.We have used an electronic Rx program for 10 years and transmitted prescriptions using Sure Scripts for over a year and we might not meet this requirement.

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For example, I just saw a patient who is not sure of the copay and deductible for his prescription.Instead of sending two antibiotic prescriptions to the pharmacy electronically, I gave him two computer-generated prescriptions on paper.He will take both to the pharmacy and ask about pricing before deciding if the extra cost is worth the extra convenience.

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Another example involves ear infections. There is excellent data that 85% of all ear infections clear without antibiotics and recent guidelines recommend waiting two days before starting a prescription. Again, I give a computer-generated prescription on paper to the family with plans to fill the prescription if symptoms persist for more than two days. In both these circumstances, the paper prescriptions are for patient convenience and/or appropriate medical care and yet would not count towards this objective.

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Finally, the proposed regulations for electronically transmitting prescriptions for controlled substances are extremely onerous and I suspect few providers will avail themselves of the opportunity. Thus, all controlled substances will be printed on paper.

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I suggest a lower threshold for electronically transmitting prescriptions. Alternatively, exempt controlled substance prescriptions from the denominator and allow the provider to flag certain prescriptions as printed for patient convenience or for medical considerations.

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With regards to Clinical Summaries, I would prefer that patient access to the information via a web portal be counted as providing a clinical summary. I rarely finish my notes at the time of the visit and only finish 90% of my notes on the same day of the visit. Some of partners finish their notes two or three days after the visit. It would be a significant burden to have to print out the plan for every patient at the time of the visit.And in fact, sometimes my plan changes as I think more about the case at the end of the day and decide to add extra labs or Xrays to the plan. I suggest extending the timing to within 72 hours for access to a given encounterâs information.

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The HIE requirement is also quite steep. A bidirectional connection requires a willingness on the part of the HIE to adapt to many different EMRs and some smaller organizations with exotic or home grown EMRs might not be able to meet this requirement. As for having connections with 30% of my referral network, that would be wonderful but requires action that is largely outside my control.

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As for the objective that lists âcare team membersâ, I am not sure of your goal.Which members do you want listed and why?Does that include my office staff? Or are we talking about therapists and consultants?A bit of clarity here would be helpful.

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The goal for a bidirectional connection between an EMR and an immunization registry is worthy but again, might be difficult for all EMRs. I also hesitate because I have found the data in my stateâs registry is not always accurate. This might be due to the âgarbage in, garbage outâ phenomenon.

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For example, when I started submitting data to the state IIS, I had to have my IT person data-mine the EMR to find which vaccines to upload using the required file specifications. We found that we could not necessarily look at the individual vaccine cells to decide if a vaccine was given because the providers would put notes in there to clarify a situation. For example, if the HIB was unavailable due to a national shortage, we wrote that in the cell to explain why the HIB was not given that date.We have since changed our protocols but we had eight years of data to clean up before submitting the vaccines to the IIS.

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Finally, as for allowing group reporting, I would strongly be in favor of this option.